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Imports and Exports: Americans Shop the World for Food Every Day of the Week

Trade experts say we should not expect to see a decline in food exports and imports when figures become available for Oct. 1-16, 2013, the period of the partial government shutdown.

They say that global food trade is now too robust to be slowed just by a few U.S. Food and Drug Administration inspectors being off the job for a few days. Nothing FDA did slowed the flow of food across borders, and world food safety is mostly in the hands of the industry and various systems than with any one government.

“We saw no slowdown at all at FDA,” says attorney Ben England at the worldwide consulting company known as FDAImports.com.

“In fact, we got more done than usual during the shutdown,” says England, who previously worked at FDA for 17 years. He says that agency production probably improved “because they were not doing all their regular non-essential activities.”

U.S. food imports are experiencing brisk growth this year, up more than $3 billion through the first eight months of the year.

In August – the most recent month for which import-export data are available – the U.S. exported $10.15 billion worth of foods, feeds, and beverages, while imports in the same category totaled $9.566 billion.

By comparison, the last estimate out of USDA of the “direct-to-consumer” market was just $1.2 billion a year. And while U.S. food exports continue to exceed imports – mainly because of huge grain and growing meat exports – the demand from American restaurants and grocery stores for foreign products is creating a bonanza for some.

Most South American countries, with the exception of Venezuela and Suriname, are now net exporters of food. The largest is Argentina, which exports $23.42 worth of food for every $1 it imports. Even several African countries are now net exporters of food.

One measure of how food safety for the United States is spread all over the world comes from one of the anti-terrorism measures taken after 9/11. For a decade now, every food manufacturing and warehousing facility has been required to register with FDA, including those overseas that might want to export to the U.S.

At last count, there were 449,859 registered food facilities, with 278,307 being of foreign registration and 171,552 being domestic registrations. Among the top foreign locations are: Japan (28,223); China (26,743); Mexico (23,829); Canada (16,509), and France (16,162). Even countries such as Peru, Thailand, and Columbia have more U.S.-registered food facilities than Oregon, Missouri and Virginia.

At the time the Food Safety Modernization Act (FSMA) was signed into law, FDA was conducting fewer than 200 foreign food plant inspections a year. At that rate, it would take 1,391 years to inspect all the foreign registrants.

FSMA definitely recognizes the need for FDA to step up its game, especially when it comes to foreign inspections. The law, based on risk, now mandates inspection frequencies. FDA is to inspect 600 foreign facilities and then double that number in each of the next five years.

That translates to 9,600 foreign inspections annually, a frequency that would mean FDA could get around to all foreign registered facilities in just 28 years. Higher-risk facilities will get priority under FSMA, which also gives the agency access to company records and food-safety plans.

FDA also uses a risk-based approach to food and beverage products entering the U.S. and estimates that only about 2 percent is actually subject to physical inspection. With the increasing volumes of imported food, FSMA gives FDA more tools to protect food safety.

One is that the agency only has to accept accredited laboratories conducting food testing, and the other is to enlist qualified third-party auditors to help police all those foreign food facilities.

Those non-governmental solutions mean that the percentage of the world’s food-safety system relying on the private sector is growing. Some say that’s all part of the plan.

World food trade was not as large as it is now when the Global Food Safety Initiative got under way in 2000 as a project of the Consumer Goods Forum, representing 400 retailers, manufacturers, service providers and others from 70 countries.

The private sector-led GFSI says that it works for harmonization of food-safety standards worldwide to reduce audit duplication in the supply chain through benchmarking and equivalency models for food safety. It also advocates for flexibility and market choice.

On issues such as accreditation of laboratories and qualifications for third-party auditors, GFSI engages FDA through a continuing series of meetings, conferences and white papers.

When little-known imports such as Egyptian fenugreek seeds, pomegranate seeds from Turkey, or pepper from Vietnam are increasingly coming up as the causes of foodborne illnesses in the U.S. causing sickness and death, there is a concern that the FSMA reforms cannot occur fast enough.

“With many ingredients sourced globally, and with increased requirements to understand the complete supply chain, many food-safety management programs contain clauses requiring supplier verification,” says Robert Rogers, senior advisor for food safety and regulation for Mettler Toledo, a global manufacturer and marketer of precision instruments for use in laboratory, industrial and food retailing applications.

“There are cases where a contaminated raw ingredient makes its way into several different products, creating a recall nightmare,” Rogers told Food Safety News. “Inspecting raw ingredients for contamination, including physical, not only reduces the likelihood of contamination reaching the end consumer but also helps to identify the root cause, and proper effective corrective action can be applied.”

“FDA is to inspect 600 foreign facilities and then double that number in each of the next five years.

That translates to 9,600 foreign inspections annually, a frequency that would mean FDA could get around to all foreign registered facilities in just 28 years.”

This FSMA mandate is not being met, and will not be met until funds are appropriated to cover the cost. I believe FDA’s intention is to maintain current numbers of foreign food inspections, ~1200 – 1300 per year.

Thomas O. McGarity

While the FSMA requires the FDA to inspect 600 foreign facilities in 2011 and then double that number for the next five years, the agency itself has acknowledged it will never be able to reach that goal due to lack of funding:

“For foreign inspections, FDA has increased its coverage to 1000 foreign food facilities in FY 2011 and 1200 foreign inspections in FY 2012. The agency does not expect to go significantly beyond that level in the foreseeable future. Reaching the goal of 19,200 foreign inspections [in 2016] called for by FSMA would require hundreds of millions of dollars in new funding, which the
agency cannot realistically expect to receive.” (from p. 25 of FDA’s April 2013 report to Congress: http://www.fda.gov/downloads/Food/GuidanceRegulation/FSMA/UCM351876.pdf)

A pretty sad state of affairs. Instead, the agency says it will spend its few resources on implementing the FSMA toolkit for imports (foreign supplier verification program, voluntary qualified importer program, accredited third party auditors, and comparability assessments of foreign food safety systems). I honestly hope those programs are able to leverage private-sector and foreign-government resources in an effective way. But there’s just no substitute for FDA inspections in many cases. The number of company-paid audits that have given excellent scores to farms or processors right before an outbreak speaks for itself. We all need to stay vigilant in making sure that public health is put first as the FDA implements these rules. Unfortunately, the White House already weakened the FSVP rule before it was even released: